2. Identification of the processing representative and of the data protection officer
3. What personal data is processed by PMV and for what purposes
Personal data' shall mean any information relating to an identified natural person ('data subject'): 'identifiable' shall mean any natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Below you will find an overview of the personal data that PMV processes of natural persons, as well as for which purposes:
|Purpose(s) of processing||Type of personal data|
|Communication and marketing, in particular the sending of our newsletters, annual reports, press releases and invitations to the New Year reception.||Surname, first name and email address ("Contact details") and business card|
Communication and marketing, in particular the listing of portfolio companies on our website, facebook page or in our annual report.
Image, voice, photo and name ("Testimony data")
Facilities, in particular the registration and registration of visitors, parking management, security and access within our buildings, fire safety, access badges.
Surname, first name and registration plate of vehicle ("Identification data")
Facilities, especially camera surveillance for theft prevention and security.
Finance, in particular the execution of payments to (business) relations and service providers.
Contact details and bank account number
Selection and recruitment, in particular the selection process of applicants.
CV , personality analysis, Linkedin ("Application data") and if you provide us with reference(s), PMV may contact these reference(s) for information if necessary for the position for which you are applying.
Investment activities relating to, inter alia, corporate loans, venture capital, real estate, infrastructure and energy investments, guarantees, consisting mainly of a pre-investment phase and a post-investment phase. During the pre-investment phase, the processing of personal data will take place, among other things, for the analysis of the investment file, the performance of a due diligence, the appointment of a consultant and the taking of an investment decision and the negotiation and conclusion of an agreement. During the post-investment phase, the processing of personal data will, among other things, take place for the execution of the agreement, the continued analysis and follow-up of the investment file or an exit from the investment file.
Contact details, telephone number, photo, video, date of birth, civil status, financial, corporate and economic information (e.g. business plan, professional experience and skills, CV, shareholders, directors,...), copy of passport.
4. On what legal basis does PMV process your personal data?
PMV only processes your personal data when:
- the data subject has given us permission to process his/her personal data for one or more specific purposes, for example:
- for the processing of contact data in the context of communication and marketing;
- processing is necessary for the performance of a contract to which the data subject is party, or to take measures at the request of the data subject before and with a view to the conclusion of a contract, for example:
- for processing Application data and contacting references voluntarily communicated in the context of selection and recruitment;
- for the processing of your personal data within the framework of our investment activities;
- for the processing of Contact Details in the context of payment to business relations and service providers;
- the processing is necessary to comply with a legal obligation imposed on PMV:
- to process certain personal data for the purpose of identifying our business relationship (anti-money laundering legislation);
- the processing is necessary for the purposes of safeguarding the legitimate interests of the PMV or of a third party, except where such interests are overridden by the interests or fundamental rights and/or freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child, for example:
- for the processing of Contact Details in the context of communication and marketing if you are a business relation of PMV;
- to process the personal data on your business card if you have given it to a PMV employee in order to be contacted for a specific purpose (e.g. to send you concrete information about one of our specific investment activities) and to invite you to subscribe to our newsletter;
- for the processing of Identification Data within the framework of visitor registration and the processing of camera images within the framework of theft prevention and security in order to protect our professional interests, our property and staff, to ensure that all authorised persons enter our site and to be able to identify and investigate irregularities in it.
5. How does PMV get your personal information
The personal data processed by PMV are collected as follows:
5.1. Personal data collected directly
PMV processes personal data that we receive directly from you when you:
- Communicates your personal data to us for selection and recruitment purposes, or as part of our investment activities;
- is on our site (camera images);
- subscribe to our newsletters;
- submit an application file as part of our investment activities.
5.2. Personal data collected indirectly
PMV also processes personal data that we receive via:
- Press agencies and media companies for sending out our press releases (e.g. Contact details of journalists);
- recruitment agencies and our external service provider as part of our selection and recruitment process;
- External public sources for economic, corporate and financial information such as the Belgian Official Gazette, the Crossroads Bank for Enterprises, the National Bank of Belgium, Linkedin, or your company's corporate website, etc. in the context of our investment activities.
6. How long does PMV retain your personal data?
PMV does not store and process your personal data for longer than is necessary for the above-mentioned purposes for which the personal data are collected.
Personal data that we obtain in the context of our investment activities are kept in the investment phase up to 10 years after the date of the decision on the application file, and in the case of a positive decision up to 10 years after closure of the file in the (post)investment phase.
Personal data obtained in the context of the application process will be kept for as long as necessary for the application process and up to 1 year after completion of the application process in the case of non-recruitment. Upon recruitment, the Application Data will be included in your personnel file and retained in accordance with the applicable retention periods.
Camera images from the security cameras in and on our site are kept for 1 month after your visit, except if requested by the police, the public prosecutor or our legal department in case the camera images indicate potential criminal activities and/or incidents, in which case they are kept until the complaint is settled.
Personal information that we collect through the website (e.g., when you subscribe to our newsletter) is tracked until such time as you notify PMV that you no longer wish to receive our mailings, or if it appears that your email address is no longer in use.
All email communications with us are stored in our backup system for a period of 1 year after the retention periods mentioned above.
7. Who has access to your personal data
7.1. Within PMV and PMV group
PMV staff will only have access to your personal data to the extent necessary to perform their duties. Our employees are contractually bound to treat personal data as strictly confidential.
7.2. PMV service providers
This applies, for example, to parties from whom PMV purchases licenses for software or hardware systems, to the companies that help organise our events and send out our invitations. This also applies, for example, to parties commissioned by PMV to carry out payroll administration or other assignments in connection with the administrative processing of personnel policy.
A data-processing contract will be concluded with each processor, setting out the subject matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects, and the rights and obligations of the processor and the controller.
7.3. Competent authorities
PMV may disclose your personal information to competent authorities (including, but not limited to, the police authorities, courts, government authorities) when PMV determines that such disclosure is necessary (i) pursuant to applicable law or regulation, (ii) in connection with judicial inquiries or inquiries (iii) for the purpose of carrying out or defending in court the interests of PMV.
7.4. Auditors, consultants and legal service providers
PMV may provide its auditors, consultants and legal service providers with access to your personal data in connection with the (legal) services they provide to us and to the extent that this is necessary for, and is limited to, the (legal) services they provide.
7.5. Transfer of personal data outside the European Economic Area
Personal data may not be processed outside the European Economic Area without adequate safeguards unless the country or international organisation in question ensures an adequate level of protection. In principle, PMV does not process your personal data outside the European Economic Area. In exceptional cases (for example, through our service providers), the PMV will take the necessary measures to ensure an adequate level of protection, including standard data protection provisions adopted by the European Commission.
8. What are your rights as a data subject
If you have provided PMV with your personal data, you have the right at any time to request us to disclose, free of charge, what personal data we have in our possession and, if necessary, to have these personal data corrected, limited or transferred in electronic format or to have them removed free of charge. Insofar as the personal data in PMV's possession are kept for the purpose for which they were obtained and within the corresponding retention periods, PMV is under no obligation to comply with this request. In that case, the PMV will examine whether it is possible - and to what extent and under what conditions - to comply with the request, in accordance with the requirements of the legal and regulatory framework.
Furthermore, you have the right to revoke your consent to the processing of your personal data at any time. However, this revocation shall not affect the lawfulness of the processing of your personal data for the period prior to the time of revocation.
You also have the right to lodge a complaint with a supervisory authority. For the contact details of the Belgian Data Protection Authority, please visit the following website: https://www.gegevensbeschermingsautoriteit.be/.
To exercise these rights, you can contact us via one of the following channels:
- by post: PMV S.A., Oude Graanmarkt 63, B-1000 Brussels
- by telephone: 02/229.52.30
- via e-mail: email@example.com
In order to ensure the lawful processing of personal data, the data subject will be asked to identify himself by means of a copy of the recto side of the identity card or other valid proof of identity.
9. How do we secure your personal data
PMV treats your personal data confidentially and with the utmost care. PMV protects its systems - in all reasonableness - against loss and/or against any form of unlawful use or processing. In doing so, PMV makes use of appropriate technical and organisational measures, taking into account the state of the art. Your data are adequately secured in accordance with the applicable privacy laws and regulations. The personal data you provide is stored on servers located in controlled and secure environments.
Without prejudice to the aforementioned efforts, you should be aware that there is always a risk associated with sending personal data over the Internet. We can therefore never fully guarantee the safety and protection of your personal data.